ML20091J818

Forwards Addl Info on Generic Ltr 82-33,Suppl 1 to NUREG-0737 Re Procedure Generation Package Upgraded Emergency Operating Procedures

ML20091J818
Person / Time
Site:	Point Beach
Issue date:	06/01/1984
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, John Miller Office of Nuclear Reactor Regulation
Shared Package
ML20091J821	List: ML20091J818 ML20091J828 ML20091J837 ML20091J844 ML20091J849 ML20091J856 ML20091J858
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, TAC-56311, TAC-56312, TAC-56602, TAC-56603, NUDOCS 8406060207
Download: ML20091J818 (4)

Text

'

4 8

l%sconsin Electnc eom comm 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 June 1, 1984 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Mr. J. R. Miller, Chief Operating Reactors, Branch 3 Gentlemen:

DOCKET NOS. 50-266 AND 50-301 ADDITIONAL INFORMATION ON GENERIC LETTER 82-33 PROCEDURES GENERATION PACKAGE UPGRADED EMERGENCY OPERATING PROCEDURES POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In a letter dated April 15, 1983 we provided a description of our plans and a schedule for a phased implementation and inte-gration of our emergency response activities. That information was in response to Mr. D. G. Eisenhut's letter dated December 17, 1982, Generic Letter No. 82-33, " Supplement 1 to NUREG-0737 Requirements for Emergency Response Capability". In the April 15 letter we committed to submitting a procedures generation package which would describe the methods used to upgrade the Point Beach Emergency Operating Procedures (EOP ' s) by December.ll, 1983. This date was later revised to. April 1984 and then May 1984 in letters dated August 24, 1983 and March 30, 1984.

This letter contains the procedures generation package which consists of four attachments. Attachment 1 provides a descrip-tion of how the generic Westinghouse Emergency Response Guidelines (ERG's), Revision 1, are merged with plant-specific requirements to result in the new EOP's. .Due to the number of specific items, only one example is included, howevar, the remainder will be available for review at the plant. Attachment 2 is the Point Beach EOP l Writer's Guide. Attachment 3 provides the description and procedures for the EOP verification and validation program. Attachment 4 )

provides a description of the new EOP training program for licensed )

plant operators. Each of the attachments is ar independent document '

being used to describe or perform a specific function. These documents are part of a dynamic process and are subject to change l as refinements are deemed necessary. The version in use at the l time of performing the given function will be documented.

8 6

B406060207 840601 0 PDR ADOCK 05000266 F PDR

c. . ~ w. ,

4 Mr. H. R. Denton June 1, 1984 As stated in our March 30 letter concerning upgraded

'EOP's, we currently intend to implement the new EOP's in January 1985. Should you have any further questions concerning this matter, or the material provided herein, please contact us.

l Very truly yours, d

Vice Presi ent- uclear Power C. W. Fay Attachments Copy to NRC Resident Inspector

i j ATTACHMENT 1 DEVELOPMENT OF THE EMERGENCY OPERATING PROCEDURES The emergency operating procedure package is currently under development with approximately half of the procedures in draft form. The methodology described herein is generally followed for each procedure. Some of the procedures require more reviews and revisions than others but this descrip-tion is a typical process.

Wisconsin Electric is using the Emergency Response Guidelines, Revi-sion 1, prepared by the Westinghouse Owners Group as the reference procedure set for preparing plant specific E0Ps for Point Beach. The first step is to compare the generic procedures to the in-use plant emergency operating pro-cedures and normal operating procedures to discover analogous procedures.

These analogous plant procedures are reviewed to determine which steps are action steps and which are informational. This comparison between the plant and generic procedure is done to determine which items of the plant procedure are not included in the generic procedure but should be retained in the new procedures.

Next is a review of the generic procedure by an experienced Senior Reactor Operator. This is done to determine:

- which items of the generic procedure are not applicable at Point Beach

- which steps have too much or too little detail for our operators

- which aspects of the format are perceived to be difficult or undesireable and how they could be changed

- other similar operational concerns If the Senior Reactor Operator points out apparent discrepancies between plant hardware and the generic plant, other plant resources are used for additional confirmation. These resources include but are not limited to Point Beach FSAR system descriptions, system drawings, logics, and cognizant personnel. Other plant resources are used to determine plant specific term-inology including control room annunciators, control boards, operating pro-cedures and checklists, and personnel.

When an analogous plant emergency or normal operating procedure exists, the Senior Reactor Operator is also asked to go over it and advise what steps should be included in the new emergency operating procedure.

After this information is collected, the plant procedure is written following the guidance of the plant specific writer's guide. This initial typed draft is often reviewed again either by routing to a Senior Reactor Operator or having the procedure writer go over the procedure with the Senior Reactor Operator. If changes are necessary, another draft is typed.

I

_2_

l.

This procedure is then reviewed by a subgroup of the Manager's Super-visory Staff with the procedure writer to discuss areas of improvement. A new draft was typed with these suggestions incorporated. At this time a deviation document is developed. This document describes the differences between the draft plant emergency operating procedure and the generic procedure and pro-vides justification for those differences. This document is to be used as a source document during the verification process to explain deviations and minimize discrepancies that must be resolved. These plant emergency operating procedures will be reviewed by the Manager's Supervisory Staff and approved by the Manager - Point Beach prior to implementation.

The plant specific items are too numerous to send to the NRC but will be available for audit at the plant site. Some examples of typical material prepared or used in the emergency operating procedures writing process are attached. Attachement 1.1 is an example of a plant specific emergency oper-ating procedure, E0P-0, " Reactor Trip Or Safety Injection." Attachment 1.2 is the associated Deviation Document for E0P-0. Attachment 1.3 is E-0, " Reactor Trip Or Safety Injection," the generic reference procedure from which E0P-0 was written. These documents will be referenced by the Verification example given in Attachment 3.

L